Accreditation UK Self-Evaluation on Inspection Criteria
Management Standard The management of the provision operates to the benefit of the students, and in accordance with the provider’s stated goals, values, and publicity.
Strategic and quality management
[Area of strength requires four strengths, no not mets]
M1 There is a clear statement describing the goals and values of the organisation, which is made known to all staff.
Requirements
The statement is explicit and in writing
It covers all key aspects of the organisation’s work
It is made known to and understood by all staff
The College Mission Statement is displayed on Classrooms, public areas and is linked from an FAQ as well as being referenced as a download in the College website description.
M2 The management has clear objectives for the future of the organisation and has realistic plans to achieve them.
Requirements
Objectives and plans are explicit and in writing; they relate to the statement of goals and values.
Objectives and plans are known to and understood by relevant managers
Plans set out steps needing to be taken and the time frame
Evidence of work being carried out towards the stated objectives
Our plans for the future are driven by the mission statement in M1. Melton College has decided to focus on Junior Courses and Gold Courses (40+). The provision and indeed integration of Melton Guest House, and the way this opens up the possibility to welcome more families is a natural extension of this.
At the same time, we will continue to manage an Exam Centre.
At the same time, we will continue to welcome Closed Groups (mini-stays)
Our staff requirements are evolving as we evolve to this new model. In some ways, as our plan is to do more but of fewer things, our plans represent a contraction in some respects and, as such we need to demonstrate the flexibility to do more of fewer things for the benefit of our clients. We have the capital if needed.
Specific objectives include:
The development of age and level appropriate material (Academic). This is and will probably always be ongoing
The evolution of Melton Guest House to be even more family friendly (Premises/Accommodation)
M3 There is a documented and clearly understood structure for the ELT operation. There are sufficient staff to manage and deliver the provision, and to ensure continuity at all times.
Requirements
Documented structure includes all management and administrative posts, is current and is known by staff
Cover for key posts is clear, adequate and known to staff concerned
Record keeping is accurate, up to date, comprehensive and consistent
Staff, systems and computer resources are sufficient to meet the needs and expectations of students, group leaders, agents etc.
What follows covers the structure of the whole operation. Of the three elements of the Campus; Guest House, College, Exam Centre, the first two run very closely together and we consider the service provided in Melton Guest House as being a part of our ELT provision.
We have a traditional "Our Staff" section on the website, which we are probably in the process of discontinuing in print. This is driven a) by staff changes causing constant re-prints and b) GDPR constraints. Not all staff want to be on an organogram and, with the exception of our Designated Safeguarding Lead, there is no logical necessity to force them to do so.
We also produce a "College Teams" sheet. This shows who deals with what and who leads each team. Both internally and externally, we believe this is an appropriate and helpful provision. The teams approach also addresses the need to ensure "There are sufficient staff to manage and deliver the provision, and to ensure continuity at all times".
M4 There are effective channels of communication between all involved in the ELT operation, and between the ELT operation and any wider organisation of which it is a part.
Requirements:
Clear and comprehensive lines of communication
Appropriate forms of communication
All relevant stakeholders included in communications
Intended recipients aware of important information
The three elements of the business: College, Guest House and Exam Centre work within the same two buildings on a small campus. Although the team structure can seem complex, communications between teams and within teams are continuous, straightforward and face-to-face, backed by online resources.
Our main software programmes for communication are:
Bright (incoroporating Bright HR and Bright safe and covering HR, holidays, absence, document (including must read policies such as Safeguarding) and time and attendance.
Basecamp, a project Management Application. This allows for a variety of interactions from person to person, person to group all the way up to task and finish. Basecamp is flexible and adaptive but has a couple of key weaknesses. 1) It lacks any real confidentiality and 2) although it can maintain a record, it can't really maintain a formal record. This is a potential problem, particularly where formal evidence is required. We address this, in most cases, by using Bright or Adobe Sign to get a physical, albeit electronic, record of decisions.
M5 The provider regularly obtains and records feedback from students on all the services offered. Feedback is circulated to relevant staff and appropriate action is taken and recorded.
Requirements:
Initial and end-of-course feedback taken and recorded
Feedback collated, reviewed and action taken and recorded
Staff have access to feedback relevant to their role
Feedback taken on all significant services including, e.g. accommodation and resources.
Our feedback system was completely overhauled in preparation for Summer 2023. Previously, we collected end-of-week feedback using Survey Monkey. This was efficient, as reliable as most methods (paper got a higher percentage response but not necessarily more depth). The problem with weekly feedback was data harvesting -a nightmare as, for example, views on an excursion to The Yorkshire Coast appear in surveys for Week 1,5,9. To simplify the process, we now have:
- An end of week feedback form which we invite all students (Junior and Gold) to complete.
- Individual forms for each activity. So, for example, The Yorkshire Coast Excursion now has its own survey for all 3 times we run the trip. As the survey records the date, we know if a lower level of satisfaction is perhaps due to rain or tide!
We also send a survey to all Junior student's parents and all Gold Course participants. This is sent after the course at the same time we confirm that, for those booked indirectly, we will be deleting their Emergency Contact Details. - Separately, and on paper (for now) we gather homestay feedback.
M6 The provider regularly seeks and records feedback from all staff on the services offered. Appropriate action is taken and recorded.
Requirements:
All significant groups of staff are included
Action taken is recorded
There is a formal and an informal aspect to this. Informally, within a small team, staff make comments as part of day-to-day discourse and there in an understanding that we are open to suggestions (though might choose not to implement them). Slightly more formally, we have the provision of "To-Do" lists where staff can note items for repair etc. Most formally, staff are asked regularly if they would like to feedback formally. This is done with the promise of a reply within 5 days.
M7 The provider reviews systems, processes and practices with a view to continuing improvement. Appropriate action is taken and recorded in an annual self-evaluation.
Requirements:
Evidence of planning and implementation
Feedback from M5 and M6 informs the organisation’s forward planning
Action plan showing progress on Points to be addressed (PTBA), submitted with the Annual declaration in the year following inspection
Action plan kept up to date (but not submitted unless requested)
Self-evaluation against inspection criteria submitted prior to inspection.
Our evaluation is ongoing and most reviews are done using ther project function within Basecamp. Significant recent and ongoing Projects include:
- The move to auto-emails instead of PDF attachments for information sent to parents, hosts, partners and students.
- A thorough review of safeguarding, where we have comissioned an outside expert to review our systems.
- A review of our Annual Appraisal System
- Including a review of our description of responsibilities, duties and tasks
- The Student Pathway - this is a new way to make the process from enquiry to post feedback more intuitive for students and parents
Staff management and development
[Area of strength requires three strengths, no not mets]
M8 The provider implements appropriate human resources policies, which are made known to staff.
Requirements:
Any HR policies not covered by M10–M13 or W4, e.g. terms and conditions of employment (remuneration, hours of work, leave, absence, equal opportunities, health and safety, whistleblowing etc.)
We retain the services of Peninsula, a specilist company which provides cover, advice, support and documentation for HR and HS. All our HR paperwork is cleared by Peninsula before use. Our Employee Handbook, along with relevant documents are available in the staff area of our website. Peninsula has been invaluable when problems have arrisen and on a day-to-day level, they ensure we are up to date with HR compliance.
M9 The provider specifies the duties of all staff working with ELT students, and regularly reviews these.
Requirements:
Comprehensive, up-to-date job descriptions/role profiles available for all ELT managers and staff
Agreed/known by staff
Evidence of review
This is, to date, the one area proving resistant to a move to paperless! What was Number 2 of a suite of 9 Handbooks still exists primarily in paper form. Its review and development features in the project referenced under M7 (above).
The resulting document Teams, Duties, Tasks and Goals was rolled out as part of our new Appraisals strategy and seeks to list everyone's tasks and set a Goal (softer word for performance standard).
M10 There are effective procedures for the recruitment and selection of all staff.
Requirements:
Written recruitment policy setting out procedures
Procedures implemented: ID check, references, right to work in UK, suitability checks (if relevant), verifying qualifications claimed, evidence that non-standard TEFL qualifications have been investigated.
Staff are recruited by advert or by direct, unsolicited application. All staff are interviewed, in person or online. Staff must submit a completed CV and explain any gaps (though with COVID there have been quite a lot of these!) If offered a position, staff must provide, before starting:
- Passport (or proof of the right to work in the UK
- Originals of Certificates (or formal certification of copies)
- Recent DBS, or access to an update service check
- Starter form (for payroll)
- Signed SMT (Statement of Main Terms) which, in turn, references the Employee Handbook
We have a Recruitment Policy, edited and updated in the light of NSPCC Training taken by the Principal
M11 There are effective induction procedures for all staff.
Requirements:
Written induction procedures
Records of induction
Induction includes basic H&S and other items relevant to the role and the type of provision
Most induction is one-to-one and delivered by someone in a position akin to line manager. We have a small team and there is always someone on hand to show and explain. However, mindful that this leaves no objective trail, we have added an element to the document referenced in M9, which will require a formal "sign-off" for duties. Other necessary elements are covered by an induction checklist, developed in April 2022 (and itself a development of previous lists. With the implementation of Bright, a lot of the "documents you need to read" side of things can be automated and followed-up
M12 There are effective procedures for monitoring and appraising all staff, and for handling unsatisfactory performance or conduct. These procedures are made known to all staff.
Requirements:
All staff have a line manager
Written monitoring and appraisal procedures
Records of monitoring and appraisal
Written policy for handling unsatisfactory performance: disciplinary and capability procedures.
There are four elements to this
- The formal HR approach is covered by documentation and processes, covered by our contract with Peninsula
- One of our developmental projects in 2023 focussed on our Appraisal cycle.
- Staff are guided and monitored by our "Teams, Duties, Tasks and Goals" document
- For teaching staff there is also a programme of observation (informal and formal). If possible, teaching staff are also encouraged to participate in peer observation.
M13 There are effective procedures to ensure the continuing professional development of all staff to meet the needs of the individual, the students and the organisation.
Requirements:
Written procedures for continuing professional development (CPD) relevant to role.
Records of CPD
As with induction, positive aspect of a small team in a small College is that a lot of CPD can be continuous and (in a positive sense) ad hoc. This leaves two problems to address:
- The approach leaves only a limited trail
- The approach can overlook the need for more formal sessions, especially the sort which, only taking 20 mins or so, can be seen as an interruption, especially on a busy day!
At the Macro end, things are easier. We provide external training courses, where requested or where seen as necessary. For example, we run 1-day EFAW (Emergency First Aid at Work) courses for all staff, Food Hygine, PAT Testing etc as appropriate. All staff do at least a basic safeguarding course. Teaching staff have attendance at the EnglishUK North Academic Conference and have their membership of IATEFL paid for by the College. In return, we "suggest" a suitable SIG to join!
We encourage all staff to maintain and share a CPD Log. In addition, we are now keeping a record of the more formal training offered.
Student administration
[Area of strength requires three strengths, no not mets]
M14 Staff are helpful and courteous to students and their representatives, and provide satisfactory levels of customer service.
Requirements:
As Criterion
I hope we do!
M15 Students or their representatives receive sufficient information and advice on their course choices before arrival and during their stay.
Requirements:
As Criterion
Again, I would hope this is the case. We only really have two courses and these are described (I hope) simply and clearly on our website. I do not include Closed Group Courses (Ministays) in this as they are always, in effect, bespoke.
On a broader front, we try to provide useful/necessary information to applicants. The best example of this is probably our pre-arrival slideshows, sent to all students. There are versions for Junior and Gold. (follow the links)
M16 Staff carry out enrolment, cancellation and refund procedures efficiently, fairly, and with appropriate sensitivity.
Requirements:
Written procedures including, where relevant, a standard clause in their booking terms and conditions stating the following, or a variant on it:
If a visa application is rejected and we receive written evidence at least xx days prior to arrival, we will refund the fees received in full, less an administrative fee of yy. Where we receive this evidence, the refund will be paid to you within four weeks of your providing us with bank details and signed authorisation that the refund should be paid to that account. If written evidence of a refusal is received less than xx days prior to arrival then the refund will be paid less the administrative fee and the following non-refundable payments: zzz.
We try to respond to all applications within one working day and, ideally, within 4 working hours. We have a cancellation policy which 99% of the time we go well beyond. For example, during COVID we allowed anyone to cancel or postpone (with the fees locked for 18 months).
M17 There are effective systems in place to maintain accurate and up-to-date records of student enrolment, payment and course details. These records are accessible at all times to authorised staff.
Requirements:
As Criterion
The College administration is run on a database, written in-house to our specification. This covers most of the areas covered in M17 with additional support from a networked version of SAGE (which is also our accountancy software).
M18 There are effective systems to maintain up-to-date and accessible records of local contact details for students, and their designated emergency contacts.
Requirements:
Every student record holds local contact details and next of kin or other emergency contact
Information available to emergency phone holder
Records complete and students reminded to update if there are any changes.
Local Contacts. The vast majority of students live in our homestay or in Melton Guest House. For those in their own accommodation, we insist on this being provided in advance and we then verify the information, when the student arrives.
Emergency Contacts. This information is sought for juniors:
- At application (if online)
- On the parental Consent Letter
- On arrival (on paper)
For Gold Course, the information is sought on arrival, on paper.
The paper records are transferred to our system during the students first day and we also check that the students phone number is working. For junior courses, we also have a parents' WhatsApp Group.(In passing, we also have a WhatApp group for hosts of current students).
The big exception to this is for closed groups, travelling with leaders. For closed groups we make clear that our expectation is that the leader will have the Emergency Contacts for the group. Of course, on arrival, we get the leaders' contact numbers and add them to a WhatsApp group.
M19 There is a clear and effective policy on student attendance and punctuality that is known to all staff and students and is applied consistently.
Requirements:
Written policy for all students, in clear language
[An area which has simplified considerably since abandoning adult General English! ]
For Juniors, the rule is simple: You attend all classes, and all mandatory activities. We also expect 100% punctuality and check the arrival of students within 5 mins of the start of their first lesson. We note lateness on the Register but our "Care of Juniors" form is more important as it marks their arrival and departure at the beginning and end of each day. Juniors are not allowed off campus, during the day.
For Gold Course we are less strict but do speak to participants if their absence (or more importantly, punctuality) is disrupting the class.
M20 All staff and students are made aware of conditions and procedures under which a student may be asked to leave the course.
Requirements:
As Criterion
This is covered by an FAQ
https://www.melton-college.co.uk/faq/do-you-ever-ask-students-to-leave-the-college/
M21 All students and, where appropriate, group leaders and parents/legal guardians, receive information in writing about how to make a complaint.
Requirements:
Written procedure for complaints given, or made available, to all students (group leaders and parents/legal guardians) as part of enrolment process or at start of course – written in accessible language.
Record of any complaints and action taken.
This appears as an FAQ in our website but is also explained, and linked by QR on notices throughout the College
https://www.melton-college.co.uk/faq/how-can-i-make-a-complaint/
Publicity
[Area of strength requires three strengths, no not mets]
M22 All publicity and information is accurate, and gives rise to realistic expectations about the premises, location, and the extent and availability of the services and resources.
Requirements:
As Criterion
We believe this to be the case (though it is hard to evidence without visiting).
M23 All publicity and information about the provider and the services it offers is in clear, accurate and accessible English.
Requirements:
Accessible to speakers of English at level B1 of the Common European Framework of Reference, or in translation – languages for relevant markets.
We think this is the case. We have tried to structure the site so that the more complex nitty-gritty is not the first page. Obviously, this needs to be balanced with compete information.
M24 Publicity gives clear, accurate and easy-to-find information on the courses.
Requirements:
Easy to access in main section of publicity
outline description of each course, including objectives and levels
times of classes, any private study periods
total number of taught hours per week
course dates and any non-teaching days within the course
minimum enrolment age and, where courses enrol only under 18s, maximum enrolment age
the maximum class size
We have tried to maintain a simple "no more than three clicks" approach and have all the course pages set out in the same format.
M25 Publicity includes clear, accurate and easy-to-find information on costs.
Requirements:
The cost of:
Tuition
any teaching materials which students are required to buy
any accommodation offered
The approximate cost of:
any leisure programme not included in the course fees
any course-related examination fees not included in the course fees
Requirements for deposits, payment of fees, and the refund policy, (including the arrangements and deadlines for cancellations.)
All course pages have a clear FEES page giving the total fees for the most popular lengths of stay etc.
M26 Publicity or other information made available before enrolment gives an accurate description of the level of care and support given to any students under 18.
Requirements:
Full and accurate statement of pastoral care, including details of:
supervision outside class times
arrangements (if relevant) for journey from accommodation to teaching centre
limits to supervision of 16 and17 year-olds on adult courses
We have a comprehensive but we hope also accessible section of our website. In addition, at each stage of the "Student Pathway" we encourage interaction.
M27 Publicity gives an accurate description of any accommodation offered.
Requirements:
Provider makes it clear if accommodation offered is arranged by an agency
Types of accommodation offered are clearly described
If provider places a student in accommodation described as homestay there will be no more than three other students (or other paying guests) staying (whether placed by the provider or another organisation.)
Where a student is expected to share a bedroom with another student, this is clearly indicated
Services, including arrangements for cleaning, supply of towels and bedding, and laundry, are clearly described
Realistic estimate is provided of the time, distance and cost of travel from accommodation to the provider
We offer two accommodation options and believe these are described openly, fully and clearly.
M28 Descriptions of staff qualifications are accurate.
Requirements:
Any description of staff qualifications and experience is accurate and applies to the full range of staff at any time
Any classes or courses which are used for teacher training purposes (with unqualified teachers) are so designated, and are provided free of charge or at substantially reduced cost.
We limit ourselves to saying that staff are qualified and, beyond that, we reference their actual qualifications
M29 Claims to accreditation are in line with Scheme requirements.
Requirements:
All eligible provision is declared for inspection as set out in 1.3 Scope of accreditation
Any claims to accreditation, or registration of accommodation agencies, are in line with the guidelines set out in 3.1 Claiming accreditation, and are not applied to unaccredited or ineligible provision
They are
Premises and Resources The premises provide students and staff with a comfortable and professional environment for work and relaxation. A range of learning resources is available, appropriate to the age and needs of the students. Guidance on the use of these resources is provided for staff and students where needed.
Premises and facilities
[Area of strength requires three strengths, no not mets]
P1 Premises, including any external areas, are in a good state of repair, cleanliness and decoration, and provide a comfortable environment for students and staff.
Requirements:
Adequate
circulation space
storage space
toilet facilities
Most of our repair and renewal programmes were suspended during COVID but are now being restarted. Regular cleaning is provided by a local contractor and we also retain contractors for decoration, plumbing, electrical and joinery.
P2 Classrooms and other learning areas provide a suitable study environment.
Requirements:
Adequate in size and number
Adequately lit, heated and ventilated
Free from disruptive extraneous noise
Furnished for sufficient flexibility of layout
Arranged so that all students can see, hear and write in comfort
We feel they do and have invested over the years in upgrading facilities in our classrooms
P3 Students have adequate room and suitable facilities for relaxation and the consumption of food.
Requirements:
As Criterion
Obviously this is stress tested in bad weather so our rules on, for example, eating in classrooms are relaxed in such circumstances. We built a new much larger Conservatory some years ago, primarily to cover wet/cold weather options. Our covered Table Tenis area is being re-roofed this autumn as it provides a wet weather option (though students would need to dress warmly.
P4 Free drinking water is available. A choice of appropriate food at affordable prices is available to students on site, if not available locally.
A criterion in two parts. We have three drinking fountains around the College and, of course, allow students to drink water in class. We have a small cafe/coffee shop and, of course, all students in our accommodation, homestay or Melton Guest House, are on full-board.
P5 There is adequate signage to buildings, routes, rooms and exits, and there are facilities for the display of general information.
Requirements:
Clear indications of how to move around the building/campus and locate the various rooms and services
Clear exit signs and fire evacuation procedure notices
We have general directional signage to all rooms. We have emergency signage as well as signage advising (for example the CCTV coverage) and restricting, for example the Smoking area. All classrooms have an enclosed notice board for general information and a pin board for room/class specific information.
P6 There is sufficient space for all staff, for meetings, relaxation and the storage of personal possessions, and for teachers to carry out their preparation and marking.
Requirements:
As Criterion
Staff have use of a staffroom and a staff sitting room. The latter has a kettle, fridge and microwave.
Learning resources
[Area of strength requires three strengths, no not mets]
P7 There are sufficient learning resources for the number of students enrolled, appropriate to their age and the level, length and type of courses offered.
Requirements:
As Criterion
We possess a wealth of legacy material but, since the simplification of our Course Structure, not focus on internally created worksheets, photocopiable resources supplemented by online materials, primarily through subscriptions to One Stop English and Linguahouse, as well as free resources from The British Council. We also adapt learning materials from venues, from example from the York Archaeological Trust and York Minster .
P8 There are appropriate resources for teachers, which are adequate in number, accessible, and well maintained and organised.
Requirements:
As Criterion
There is a small library of reference books available to teachers - often bought in response to a particular situation (see above). Staff also all have ready access to a PC in the staffroom (for all but the busiest times, unshared) and a PC in their classroom, linked to our resource bank.
P9 Any educational technology inside the classroom and elsewhere is well maintained with adequate technical support. Staff receive appropriate training in using the available technology to support learning.
Requirements:
As Criterion
We have either an IWB, PC+TV or PC+Projector in the classrooms we use. Staff are trained in their use, though, often and this needs to be stressed as ad hoc "on the job" training.
P10 Any facilities provided for additional or independent learning are appropriately equipped and organised.
Requirements:
Note ‘any’: it is not a requirement that an organisation provides facilities for additional or independent learning unless they are advertised or necessary to meet the learning aims of the students.
As Criterion
We withdrew from a formal provision of independent learning when we changed our course structure.
P11 Students receive guidance on the use of any resources provided for independent learning.
Requirements:
As Criterion
We withdrew from a formal provision of independent learning when we changed our course structure.
P12 There is a policy for the continuing review and development of teaching and learning resources, and evidence of its implementation.
Requirements:
Evidence of planning and implementation
Informed by staff and student feedback
The simplicity of most materials being in-house is that the review of materials is built into their use. Our lesson records (for historical reasons known as T-Cards) allow for staff to make observations on how the material worked in class. Closed groups are set up with the material selected - and therefore discussed- in advance. Our Gold Courses tend to be team taught allowing the staff involved to compare materials.
Teaching and Learning The academic staff team has a professional profile (qualifications, experience and continuing professional development) appropriate to the context. Teachers receive sufficient guidance to ensure that they support students effectively in their learning. Courses are structured and managed to provide the maximum possible benefit to students. The teaching observed meets the requirements of the Scheme.
Academic staff profile
[Area of strength requires two strengths, no not mets]
T1 All academic staff have a level of education normally represented by a Level 6 qualification on the Ofqual register of regulated qualifications.
Requirements:
As Criterion
Exceptionally, the employment of any academic staff without the appropriate general level of education may be acceptable with the provision of a valid rationale.
All staff have a level 6 qualification with the exception of one for whom a rationale has been posted with the Stage 2 documents.
T2 The teaching team has ELT/TESOL qualifications relevant to the courses they are teaching.
Requirements:
Teachers of courses for students under 18 hold at least a TEFLI qualification or have appropriate qualified teacher status.
Teachers of courses for adults hold at least a TEFLI qualification.
Teachers of teacher development courses and EAP courses hold at least a TEFLQ qualification.
Teachers on ESP courses other than EAP have relevant specialist qualifications or experience at an appropriate level
ISC: All subject-specific teachers hold teaching qualifications relevant to the courses they are teaching; they also hold at least a TEFLI qualification, or have received specialist training to equip them to meet the needs of EAL students
Exceptionally, the employment of any academic staff without ELT/TESOL qualifications that meet Scheme requirements may be acceptable with the provision of a valid rationale.
All our adverts give Degree + TEFLI as our baseline. Our current staff table shows those who exceed this
T3 The teaching team has a range of experience, knowledge and skills appropriate to the courses offered and the needs of the learners.
Requirements:
As Criterion
In a time where teachers are in short supply this is to some extent, aspirational
T4 The academic manager/academic management team has an appropriate professional profile to provide academic leadership.
Requirements:
They are academically and ELT/TESOL qualified as appropriate to the range of courses on offer; at least one person has, as a minimum, a TEFLQ qualification
They all have at least three years’ full-time relevant teaching experience
Exceptionally, the employment of any academic managers without the appropriate qualifications or experience may be acceptable with the provision of a valid rationale.
Finding one individual with the complete skill set was a challenge and removed the opportunity to play to strengths that are afforded by a team approach. The Academic Management Team has evolved and, with the recent addition of Alicia Gent will, I hope, give a firm basis for future development.
Academic management
[Area of strength requires three strengths, no not mets]
T5 Teachers are matched appropriately to courses.
Requirements:
Teachers’ qualifications and or experience inform deployment
Where possible, for example we deploy those with experience of younger juniors to the younger classes. In the case of a recently appointed teacher (Oscar Powell), the appointment was driven by his suitability as a teacher for our Gold Course. We took a short contract member of staff over Summer 23 specifically for her Primary QTS status.
T6 There are effective procedures for the appropriate timetabling of students, teachers, courses and classrooms.
Requirements:
As Criterion
Nearly all timetabling and allocation is done by the Principal. As a small school, with few classrooms, we avoid reaching capacity. Most timetables are planned some weeks in advance with, if needed, alternatives available, should the result of placement procedures dictate.
T7 There are formalised arrangements, satisfactory to students and staff, for covering for absent teachers.
Requirements:
As Criterion
This is published as policy
T8 Where enrolment is continuous, explicit attention is paid to all aspects of academic management affected.
Requirements:
Course design takes account of continuous enrolment.
Teachers receive practical guidance on lesson planning and integration of new students
Attention is paid to organisational and logistical issues
All courses (except the very rare two-week closed groups) are designed on the assumption some students will start at the beginning of each week and some will leave at the end of each week. Sometimes in summer it is possible to plan a group to last for two weeks but this is rare and never happened in Summer 23. Our advice on planning skills-based lesson is founded on this pattern of week by week, avoiding a spill to the following week. The emphasis on linking to activities really helps in this as a week when we are going to, for example, Whitby, will have lots of opportunity to do material relating to Whitby.
We lose the chance for a longitudinal development but this would only benefit the 1% or so of students staying long enough to notice.
T9 There are effective arrangements, led by an academic manager, to ensure appropriate day-to-day guidance and support for all teachers.
Requirements:
As Criterion
We have a daily briefing, led by a member of the Academic Management team and the team (Principal excepted) share the staffroom with the teachers.
T10 There are effective arrangements for the observation and monitoring of teachers’ performance by a TEFLQ academic manager.
Requirements:
Regular monitoring observations of all teachers by TEFLQ member of staff at least once a year.
Observation process includes appropriate feedback and action planning to improve and develop teaching
Particular care is taken to monitor and guide inexperienced teachers, those whose classroom performance exhibits weaknesses and those whose student feedback indicates dissatisfaction with their teaching
Richard, our DoS is responsible for observations, both formal and short drop-ins. These are recorded and the formal observations discussed. We also facilitate, when staffing permits, peer observation.
Course design and implementation
[Area of strength requires three strengths, no not mets]
T11 Course design is based on stated principles. There is a coherent and appropriate course structure described in writing for teachers’ guidance.
Requirements:
Clear rationale for structure of course, choice of coursebook and materials to be used by teachers
Course has clear ‘fit’ with needs and objectives of the students
Our courses are skill-based, with an emphasis on communication and seek to make the most of our students' time with us by integrating as far as possible material with our activity programme.
We gave up coursebooks when we stopped offering Adult General English. The move was already to photocopiable (now downloadable) resources. We have a bank of resources to which we are actively adding our materials relating to activities and the students time with us in York.
T12 Course design is regularly reviewed in light of the different and changing needs of students and feedback from teachers and students.
Requirements:
Evidence of planning and implementation
The design is continually reviewed and staff are encourage to comment on the materials selected or selected for them. The mechanism for populating lesson records with pre-written activity descriptions is the direct result of a suggestion from a current staff team member.
T13 Written course outlines and intended learning outcomes, appropriate to the course length and type, are available to students.
Requirements:
As Criterion
Each course has the same structure on the website: Overview, date specific, additional information. Each has a downloadable PDF outlining the course. Outcomes are necessarily quite general in type, given the length of courses.
T14 Any activities additional to English classes, and which form part of the language curriculum, encourage the acquisition of language and the development of relevant language skills.
Requirements:
As Criterion
I would point to our Lessons Out for the juniors and quite a lot of the activity programme for the Gold Course.
T15 Courses include study and learning strategies that support independent learning and enable students to benefit from their programmes and continue their learning after the course.
Requirements:
Course design and materials include guidance on study and learning strategies, which are highlighted and covered systematically.
As far as practicable. For example, we have had an INSET session on ensuring that all lessons have a stated outcome and all worksheets can be used for revision. This does, to some extent, constrain the worksheets but it makes them a more useful and reusable resource for the students, after their course has finished.
T16 Courses include strategies which help students to develop their language skills outside the classroom and benefit linguistically from their stay in the UK.
Requirements:
As Criterion
I would hope this is an outcome of the communicative nature of lessons and helped by the integration of courses and activities.
Learner management
[Area of strength requires three strengths, no not mets]
T17 There are effective procedures for the correct placement of students, appropriate to their level and age.
Requirements:
Formal procedures in place with account taken of students’ level and age
Staff involved in assessment are appropriately qualified and trained
Gold Students are placed via a Zoom Interview, almost always conducted by the DoS. Junior (open) students have an online test in advance of arrival and then short written test on their first morning. Closed groups, if they request a test, are send the same online test as the juniors. In exceptional circumstance we would also have a Zoom meeting with a junior and their parents. This is often for the youngest students as it gives a clearer picture that the online test! The written test is often the key to accurate placement as a sample of writing is a good guide to level (The Use of Essays in Placement Tests Hjort 1994)
T18 There are effective procedures for evaluating, monitoring and recording students’ progress.
Requirements:
As Criterion
The vast majority of students stay for one or two weeks. Early after placement we check how the class has settled, with the teachers. At the end of each week, we ask the teachers to identify the two strongest and two weakest (of those staying) i each level and this informs and is worked into our placement the following Monday.
T19 Students are provided with learning support and enabled to change courses or classes where necessary.
Requirements:
Learning support available and accessible
Change of course/class possible within a reasonable timeframe
Procedures for changing course/class known to staff and students
Changing course is not possible. We listen to students wishing to change level and talk to their teachers. Requests to move are based on a perception of the level, relative to work done at school. If we have mis-placed a student, we act. More often, students settle realising, for example, that they are stronger in some skills than in others. For the very small number of three/four + week students, we will discuss their progress individually.
T20 Where relevant, students are guided to select the examinations and examination training best suited to their needs and interests.
Requirements:
As Criterion
The only exam available to students is IELTS and we are happy to discuss its suitability and, if requested, offer preparation.
T21 Academic reports are made available to students on request and, in the case of under 18s, to their parents/guardians.
Requirements:
As Criterion
All students, except those in closed groups, receive a report
T22 Students wishing to progress to mainstream UK education have access to relevant information and advice.
Requirements:
As Criterion
If they (or usually their parents) ask, we help. Over the years a small number have shown interest to returning for an academic year.
Classroom observation
[Area of strength requires four strengths, no not mets]
Not met if the teaching in relation to the criterion is unsatisfactory in 20% or more of the segments observed.
Knowledge and planning
T23 Teachers demonstrate sound knowledge and awareness of the use of English and the linguistic systems underlying it, and provide appropriate models of both spoken and written English.
Requirements:
Teachers provide clear explanations and relevant examples, suitable for students’ level
Teachers produce accurate models of spoken and written English
Teachers are able to deal with students’ questions about language
T24 The content of the lessons shows that the course objectives, the learning needs and cultural backgrounds of the students have been taken into account.
Requirements:
As Criterion
Lessons build towards course objectives (as far as very short courses can have them).
T25 Lessons lead to relevant learning outcomes, made known to students and achieved through a coherent sequence of activities.
Requirements:
Intended learning outcomes are clearly identified and shared with learners.
We have focussed on lesson aims/Learning outcomes. Particularly addressing the utility of the worksheets used, after the course has finished.
Delivery and review
T26 Teaching techniques are appropriate to the focus of the lesson and to the needs of the group and individual learners.
Requirements:
As Criterion
T27 Teachers promote learning by the effective management of the classroom environment and resources.
Requirements:
As Criterion
T28 Students receive appropriate and timely feedback on their performance during the lesson.
Requirements:
Teachers use a range of correction techniques to support students and help them improve
Teachers provide positive feedback to students
T29 Lessons include activities to evaluate whether learning is taking place.
Requirements:
As Criterion
T30 Teachers demonstrate the ability to engage students and create a positive learning atmosphere.
Requirements:
Teachers engage and motivate all students.
Teachers provide clear instructions
Teachers promote positive interactions
Welfare and Student Services Standard The provision meets the needs of the students for security, pastoral care, information and leisure activities. Students benefit from well-managed student services, including, where offered, out-of-class activities and suitable accommodation.
Care of students
[Area of strength requires four strengths, no not mets]
W1 Providers ensure the safety and security of students on their premises by measures appropriate to their age and background, and the location.
Requirements:
Regular risk assessment(s) of all premises.
Record of actions to mitigate risks
Regular fire drills.
Adequate first aid provision.
Premises risk assessment are kept in Bright Safe. We retain Peninsula as our H&S consultants and they provide a annual review, which we implement and record. The fire bell is tested, weekly. 0800 in the Guest House and 1330 in the College every Monday. We hold a minimum of two complete evacuation drills every year, however, this is under review and may increase. The College first aid point is the East Room. Additional First Aid kits are located:
In the Guest House Reception
In the Guest House Kitchen
In the College Cafe
In the excursion bags
The college aims for all staff to have First Aid training if possible and, annually runs an Emergency First Aid at Work course. In addition, Andrew (formerly a First Aid Trainer) has a full First Aid at Work Certificate. The College also has a Defibrillator, located in the East Room.
W2 There is a comprehensive plan to respond to any emergency. This plan is known to all staff, and relevant elements are known to students.
Requirements:
As Criterion
A plan for W2 was submitted soon after the previous inspection. The plan has evolved and a newly edited version was rolled out in September 2023.
W3 Students receive pastoral care appropriate to their age, background and circumstances. All staff and students know the name(s) of the person or people who deal with students’ personal problems.
Requirements:
As Criterion
Posters featuring our Designated Safeguarding Lead are displayed round the College and also feature at induction. The students can also choose from our Assistant Safeguarding Leads and are encouraged to speak to the person they feel most comfortable talking to. We keep a supply of sanitary items in the Front Office.
W4 There are policies to promote tolerance and respect, and procedures for dealing with any abusive behaviour. All staff and students are aware of these.
Requirements:
Procedures for dealing with abusive behaviour by staff or students including
verbal abuse
harassment
bullying
actual or threatened violence
damage to personal property
behaviour that may lead to extremist radicalisation
Our opening student induction slide, together with our mission statement speak to all of these issues. They also receive more detailed cover in our safeguarding policy documents.
W5 Where relevant, students receive a 24-hour emergency contact number for the provider, in writing.
Requirements:
As Criterion
All students are made aware of our Emergency Number. This is on ID Cards and also features at induction.
W6 Students receive in advance information on the most appropriate forms of transport between the point of entry to the UK and the provider or accommodation, including approximate costs.
Requirements
Where transport is offered by the provider, arrangements are clear, effective and reasonably responsive to unforeseen circumstances.
As Criterion
The vast majority of students use our transfer service. A few ask us to arrange taxis. Others are dealt with on a case by case basis as they tend to be one-offs. The price and scope of the transfer service are clearly given on the website.
W7 Students receive advice on relevant aspects of life in the UK.
Requirements:
Information about:
· Personal safety and the care of valuables.
· Medical and personal insurance.
· Compliance with the law.
Other items relevant to the students enrolled.
All areas given as examples above feature at induction and elsewhere.
W8 Students have access to adequate health care provision.
Requirements:
Students are informed about their rights regarding medical and dental treatment through the NHS.
Students have full access to any medical and welfare services available in the organisation
Appropriate provision is made in the school and in accommodation
Students, especially since Brexit, are made aware of the more complex situation now pertaining to healthcare. All, but especially juniors are very strongly encouraged to take adequate insurance. Health care within the organisation is limited to first-aid.
Accommodation
[Area of strength requires four strengths, no not mets – across all sections of accommodation that apply]
All accommodation
W9 Students have a comfortable living environment throughout their stay.
Requirements:
A bedroom and common areas in a proper state of cleanliness and repair
Adequate heating and lighting
A sufficiently spacious bedroom with natural light, equipped with an adequately sized bed
Adequate hanging and drawer space for clothes
Privacy from members of the opposite sex
A table for private study (where appropriate)
Sufficient washing facilities and access to a bathroom, with baths or showers available daily
Homestay hosts treat the student as a full member of the household, eating together and sharing the common living areas.
This is outlined, clearly in our Homestay Handbook, currently transitioning to online. Homestay providers can also contact the Accommodation Manager using either the emergency phone or the Accommodation Manager's out of hours number. The same standard is maintained in Melton Guest House.
W10 Arrangements for cleaning and laundry are satisfactory.
Requirements:
Arrangements for regular cleaning of homestays
Arrangements for weekly cleaning of common areas, including bathrooms and kitchens in residential accommodation
Regular cleaning of fridges
Provision of cleaning materials where students are responsible for cleaning
A weekly laundry service or clearly explained laundry arrangements
A change of towels and bed linen each week.
Where relevant, this is set out in the Homestay Handbook. The same standard is maintained in Melton Guest House.
W11 A responsible representative inspects all accommodation (for safety and suitability) before students are placed, and at least every two years after that.
Requirements:
Checks recorded
Fire Risk Assessment
Gas Safe certificates renewed annually
Denise Lloyd, our Accommodation Manager (formerly Head of Student Services) has been with the College since 2012. She selects, visits, inducts and monitors all Homestay Hosts.
W12 Students receive written confirmation of accommodation booked, giving clear and accurate information.
Requirements:
Accurate and sufficient information about
type of accommodation
location
approximate time and cost of travel between the accommodation and teaching premises
services provided
payment arrangements (including cancellation penalties).
Where a student is expected to share a bedroom with another student, this is clearly indicated in the provider’s publicity
Conditions and procedures under which accommodation arrangements can be terminated are included.
The above is set out on the website. We provide bus passes for all students living 2km+ from the College.
W13 There are effective procedures for identifying and resolving any problems students have with their accommodation.
Requirements:
Where any accommodation is provided by an accommodation agency, procedures include provision of feedback to agency
Written feedback is gathered during the first week of stay. In addition, Denise is introduced to the students as part of the induction process. Any issues in Melton Guest House are dealt with by the Principal.
W14 Accommodation providers receive written confirmation of the rules, terms and conditions applied by the provider with respect to the provision of accommodation services.
Requirements:
Booking and cancellation arrangements are clear
Includes information on W15–W20.
These are sit out in the Homestay Handbook, paper or soon, online.
W15 Students receive meals as agreed; which offer a well-balanced diet, taking into account any reasonable dietary requirements students may have.
Requirements:
As Criterion
All students in our accommodation are on full board - Bed, breakfast, evening meal, packed lunch. Anecdotally, the hosts try hard but in the face, often, of teenage resistance to non-carbohydrate based options! Guests in Melton Guest House are also on full-board.
Accommodation: homestay only
W16 Homestay hosts accommodate no more than four students at one time.
Requirements:
As Criterion
This is our rule.
W17 Homestay hosts do not accommodate more than one student with the same language, unless the students, their agents, parents or legal guardians specifically request this in writing.
Requirements:
As Criterion
This is our rule.
W18 No more than two students share the same bedroom, unless the students, their agents, parents or legal guardians specifically request this in writing.
Requirements:
As Criterion
This is our rule but one we are very frequently asked to waive by groups.
W19 English is the language of communication within the homestay home.
Requirements:
As Criterion
It is.
W20 Hosts ensure that there is an adult available to receive students on first arrival.
Requirements:
As Criterion
They do
Accommodation: other
W21 Students receive information about the implications of their living in private rented accommodation and advice in case of difficulties.
Requirements:
As Criterion
We deal with this case by case. We also will need to start taking a more regimented look at privately arranged homestay.
W22 The provider monitors any other accommodation recommended, and booking and payment arrangements are clear.
Requirements:
As Criterion
Aside from homestay, the next most chosen option is Melton Guest House which we, of course, manage.
Leisure opportunities
[Area of strength requires three strengths, no not mets]
W23 Students have appropriate information about and access to social, cultural and sporting events and activities which enhance their experience of studying in the UK.
Requirements:
As Criterion
Outside of that provided as part of the course, this is dealt with case by case. Students, especially juniors, have limited free time and the vast majority of students are only with us for an average of 2 weeks.
W24 The content of any leisure programme is appropriate to the age and interests of the students.
Requirements:
Where activities form part of a course package, alternatives are available for activities cancelled for reasons outside the control of the provider
Activities form part of the package (there is a no activities Gold option). The activities are chosen to match the course including in terms of age appropriacy and interest,
W25 Any leisure programmes are well organised and sufficiently resourced.
Requirements:
Leisure programme is under the direction of a named person with specific responsibilities clearly delegated where necessary.
Jake Millson, Director of Junior Courses, takes overall responsibility for the leisure programme of all courses. Richard, Director of Studies has a closer involvement with the Gold Course Activity programme.
W26 There are effective systems to ensure the health and safety of students on all on-site and off-site activities.
Requirements:
Written risk assessments and clear guidelines on how to respond to situations where students are at risk.
Activities are risk assessed and a student friendly version of the assessment is given, if appropriate. Off-site, we maintain a suite of paperwork for students so that we can monitor their intensions. Staff on excursions - we always send 2 and aim for a ratio of 1:20, communicate by mobile (chiefly WhatsApp) but also have access to 2-way radios.
W27 Staff supervising sporting and leisure activities on or off-site have appropriate experience and training.
Requirements:
As Criterion
We have no activities which require specific training. Some risk assessments do make use of Andrew's background on Outdoor Activity leadership.
Safeguarding under 18s Standard There is appropriate provision for the safeguarding of students under the age of 18 within the organisation and in any leisure activities or accommodation provided.
S1 There is a safeguarding policy which specifies procedures to ensure the safety and well-being of all students under the age of 18. A named member of staff is responsible for implementing this policy and responding to child protection allegations.
Requirements:
Clear and comprehensive policy in place written in accessible English, appropriate to current students
Policy is reviewed annually and updated accordingly
Policy includes:
information on recognising abuse
child protection response procedures
names of Designated safeguarding lead (DSL), cover arrangements and how to contact
guidance on handling delayed suitability checks
guidance for everyone in organisation on appropriate behaviour and interaction with under 18s.
We have a Safeguarding Policy which is under continual review but stated as being reviewed annually in September. It forms part of a suite of documents covering various aspects of safeguarding which, in turn, is part of our wider commitment to the welfare of students.
S2 The provider makes the policy known to all adults in contact with under 18s through their role with the organisation, and provides guidance or training relevant to its effective implementation.
Requirements:
Policy available to all staff
Staff receive safeguarding training relevant to their role:
· all staff in contact with under 18s: Basic safeguarding awareness training (formerly level 1)
· named person/DSL: Specialist safeguarding for Designated Lead (formerly level 3)
· guidance provided to all other relevant adults
updates provided for all staff.
In 2023 we have added a formal acceptance of the various policies by all staff. All staff have basic awareness training. DSL and the two ASLs have Specialist Training and we are looking to add to additional ASLs
S3 The provider has written parental/guardian consent reflecting the level of care and support given to students under 18, including medical consent.
Requirements:
Where the provider has no direct contact with the parents/guardians, it must be clear in agreements with agents when and where this information is collected and passed to ELT provider
We collect Parental Consent Letters from all parents of under 18s, with the exception of students travelling with parents or a group leader. We make it clear to partners that we will require this information and the final stage, seeking the information in writing, is done on the first morning as a back-up.
We have an information page on the website outlining for parents what scenarios might be covered by the permission given. We are currently working on a grey areas where parents/partners make private homestay arrangements
S4 Recruitment procedures for all roles involving responsibility for or substantial access to under 18s are in line with safer recruitment good practice and the organisation’s safeguarding policy.
Requirements:
Providers must check the suitability of all those working with under 18s, as follows:
· Relevant staff members must have two references (if recruited since 1 January 2014) and relevant current criminal record/suitability checks.
· Homestay hosts must have two references (if recruited since 1 January 2016).
· Homestay hosts and all adults normally resident in the home must have relevant current criminal record/suitability checks.
Reference requests must include enquiry about suitability to work with U18s.
Where any of these are contracted by a third party (e.g. accommodation is provided by an agency) the provider must have formal agreements in place to ensure that relevant suitability checks have been done.
The College has a Safer recruitment Policy which was reviewed and updated in September 2023. Part of the review led to additional training. The maintenance of HR documentation was reviewed in early 2023 and the role was taken on by Katie Davis (Exam Centre Manager). It became clear that the files maintained pre-pandemic were incomplete and steps were taken to address this.
Homestay hosts and all adults normally resident in the home must have relevant current criminal record/suitability checks as part of our Homestay Management processes.
S5 There are suitable arrangements for the supervision and safety of students during scheduled lessons and activities.
Requirements
Students under the age of 16 are not placed in classes with students of 18 years or older.*
*Where, exceptionally, courses are intentionally provided for under 16s mixed with adults, the provider must demonstrate a sound rationale, clear recruitment information, and effective systems to protect under 16s from unsuitable materials, activities and relationships.
Sufficient adult supervision for all activities arranged by the provider, taking into account the nature of the activity, age, gender and needs of the students. (Group leaders and other adults travelling with students under 18 will be responsible only for students in their own group.)
Provision of a leisure programme appropriate to the age, ability and interests of the students (for under 16s, the cost should be included in the course fee).
Our Young-adults Course is an extension of our Young-learners Course. Together we consider them as Junior Courses with the Young-adults having additional responsibilities as a result of their age. This notwithstanding, we try to follow a policy of not having under 16s with our 18 and 19 year olds. We also try to avoid the same age gap being present in classes for those all below the age of 18. In a similar vein, material selection is an active issue for all junior students. Our worksheets are categorised as "Gold, Teen, Kid". There is always sufficient supervision during the day. During evening events, if two staff are not present, the staff leading will have easy and immediate access to assistance. On excursions, we always send two members of staff (except for closed groups) and work on a ratio of 1:20 -staff:under18s.
Each course has its own leisure programme. Where events are not included they do not form a significant part of the programme. Events are age appropriate. Some events, for example, barbecues and excursions, are shared across all course.
S6 There are suitable arrangements for the supervision and safety of students outside the scheduled programme.
Requirements
Clear rules for what students may do outside the scheduled lesson or activity times and without supervision, appropriate to the age of the students and the location
Hosts, group leaders and residence supervisors are aware of the rules (including the time they are expected to return for meals and at night)
Procedures in place to ensure these rules are adhered to.
Clear rules for what students may do outside the scheduled lesson or activity times and without supervision are explained at various stages. They are set out very clearly in the first day during induction and after that by access to the first day induction and through our use of the "Care of Juniors" form. Hosts are aware of the rules and they are set out in the host sections of the website and referenced, for good measure, using the Hosts' WhatsApp Group. The Emergency Phone, together with the Hosts' WhatsApp group ensures that we can track students who have failed to adhere to the rules and we follow this up the following day. However, I should stress that the systems are primarily for the welfare of the students, not as a means to admonish those that stray from the path. We have found that a gentle possibly gentle but firm reminder works wonders and the main deterrent is the fact that they know we care.
S7 There are suitable arrangements for the accommodation of students.
Requirements
A responsible adult (known to and vetted by the provider) is always present overnight and normally when students under 16 are at home or in residence
Providers ensure that students under 16 lodged by them or their agency in homestay or residential accommodation are not lodged with students of 18 years or older
In residential accommodation, the ratio of supervising adults to students must be at least 1:20 for students aged 12–17, and 1:15 for students under 12 at all times.
All accommodation provided by Melton College is arranged by Melton College. We have a 3/4 time Accommodation Manager who selects, inducts, visitsand manages our Homestay provision. This includes biennial re-visits and annual checks of Gas Certificates (if applicable). All adults usually resident in Homestay have a DBS check (the College has an account with Civil and Corporate. We do not place students under 16 with those over 18. The exception is in Melton Guest House where those under 18 must be with a parent or adult relative. Students living more than 2km from Melton College get a bus pass as part of their Accommodation Fee.
S8 There are suitable arrangements to ensure contact between the provider and parents, legal guardians or their nominated representatives concerning the welfare of students.
Requirements
Effective measures and information are in place to enable 24-hour contact with parents or legal guardians of students
Parents, legal guardians or agents of students have a telephone number that can be used to contact the provider outside office opening hours
We start to seek the Emergency Contact Information (ECI) from application onward. In the first instance this is passive in that the ECI is empty on the Application Confirmation. However, in linked Joining Instructions, there is a direct request for the information, which is repeated at every subsequent contact stage. If the student is applying through a partner, we also ask for the information and it is our policy that we do not accept "but you can contact us" as a substitute. The final stage is that, on their first morning, we ask all students to complete an Emergency Contact Card. This checked against information help and is securely filed. The paper version also proofs against a catastrophic data loss of significant downtime. The information is also printed and held in the Emergency Bag, (kept by the member of staff on duty).
In the other direction, the College Emergency number is prominent on the website and correspondence and is backed by the Parents' WhatsApp Group
Declaration of legal and regulatory compliance
D1 The organisation certifies that it operates at all times in accordance with the declarations below.
Inspectors may spot check elements of the legal and regulatory declaration as well as attention paid to compliance.
